ML20127B945
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UNITED STATES.
NUCLEAR REGULATORY C0ttilSSION 1
In' the' Matter of
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Docket No.
55-20551 Jinely P. Cash
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License No. S0P-20461-1 Vogtle Electric Generating Plant
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EA 91-065 DEMAND FOR INFORMATION I
J Jinety P. Cash-(Licensee) is the holder of Senior Reactor Operator License No. SOP-20461-1 (License), issued by the Nuclear Regulatory Connission (NRC or 1
Conesission) pursuant to 10 CFR Part 55 on September 16, 1988. The License authorizes the Licensee to direct the licensed activities of licensed operators
'at,'and to manipulate all controls of the Georgia Power Company's Vogtle
. Electric Generating Plant (VEGP), Units 1 and 2, Facility License Nos. NPF-68 and NPF-81, in accordance with conditions specified therein.
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3 In January 1990, NRC Region 11 received information alleging that VEGP Unit 1 i
was intentionally placed in a condition prohibited by Technical Specifications.
In response to that information, the NRC initiated an investigation to determine the facts and circumstances of the allegation. The NRC Office of Investigations completed its investigation on March 19, 1991, and concluded that Technical e
Specification 3.4.1.4.2 was knowingly and willfully violated with the Licensee's express knowledge and consent.
F-b At the time of VEGP's first refueling outage, the Final Safety Analysis Report,
. Chapter 15.4.6.2.1.1, Dilution During Refueling, required that valves 1
1-1208-U4-175, 1-1208-U4-176, 1-1208-U4-177, and 1-1208-U4-183 be locked closed j
-during refueling in order to prevent a boron dilution accident. Technical ll 6 9bf~
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I Specification 3.4.1.4.2 and VEGP Procedure 12006-C, " Unit Cooldown to Cold Shutdown," Section 04.2.14 were instituted as required to prevent such an inad-vertent boron dilution during Mode 5 reactor coolant loops not filled or Mode 6.
The Technical Specification stated, in part, " Reactor Makeup Water Storage Tank (RMWST)dischargevalves(1208-U4-175,1208-U4-176,1208-U4-177,and1208-U4-183) shall be closed and secured in position." The locking closed of these valves prevents the flow of unborated water from the Reactor Makeup Water Storage Tank into the Reactor Coolant System. At that time, boron dilution flow analyses did f
not exist for Mode 5 reactor coolant loops not filled or Mode 6 and, since these analyses had not been done for VEGP, the above mentioned valves were required to j
be locked closed. in Mode 5 reactor coolant loops not filled and Mode 6.
1 Based on the investigative findings, specifically the Licensee's testimony indicating (a) an awareness that adding chemicals at mid-loop would constitute entry into the actions statement of Technical Specification 3.4.1.4.2; (b) knowledge that valves 1-1208-U4-176 and 1-1208-U4-177 were opened in order to fill the chemical addition pot; (c) a denial that Technical Specification 3.4.1.4.2 was violated during the four occasions that the Reactor Makeup Water Storage Tank valves were opened on October 12-13, 1988; and (d) that the Technical Specification immediate action statement was adequately executed by only leaving the valves open for a maximum of five minutes, the NRC is concerned that the Licensee may have intentionally disregarded Technical Specifications in an apparent attempt to facilitate outage activities. Notwithstanding claims that reasonable interpretation of the Technical Specification would allow opening
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~ of the valves for a short time period, the NRC concludes that the wording of the 4
Technical Specifications is exceptionally clear and is not cpen to any e
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interpretation that would allow the intentional manipulation to the open position of the above-listed valves with the plant in the specified condition.
This is viewed as a particularly significant matter because of the position held by the Licensee at the time'of the event. As Operations Superintendent on Shift, it was the Licensee's responsibility to ensure compliance with Technical Specifications.
Therefore, further information is needed to determine whether the Comission can have reasonable assurance that in the future the Licensee will comply with Technical Specifications and otherwise conduct licensed activities in accordance with the Commission's requirements.
III Accordingly, pursuant to sections 161c,1610,182 and 186 of the Atomic Energy Act of 1954, as Amended, and 10 CFR 55.31(b), in order for the Commis ion to determine whether the License should be modifiec, suspended, or revoked, or other enforcement action taken to ensure compliance with NRC regulatory requirements, the Licensee is required to submit to the Director, Office of Enforcement, U.S. Nuclear Regulatory Conmiission, Washington, D.C. 20555, within 30 days of the date of this Demand for Information, the following information, in writing and under oath or affirmation:
A.
A full and complete explanation for the Licensee's activities with regard to the actions taken during the events associated with the opening of the
' RMWST discharge valves, with VEGP Unit 1 in Mode 5 reactor coolant loops not filled, that occurred in October 1988.
B.
An explanation why the Licensee should not be removed from all NRC licensed activities at VEGP for permitting subordinates to open valves 1-1208-U4-176 and 1-1208-U4-177 in October 1988 in apparent willful violation of VEGP Technical Specification 3.4.1.4.2.
C.
A full and complete discussion of the Licensee's decision making process
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l regarding compliance with Technical Specifications and the methods used to impart that process to subordinates. Specifically, the discussion
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should cover how the Licensee addresses Technical Specification require-ments he does not fully understand as well as other unusual conditions.
D.
A full and complete discussion regarding the Licensee's actions following the event and the Licensee's involvement in and information provided to the VEGP Plant Review Board in the review of the event.
Copies also shall be sent to the Assistant General Counsel for Hearings and Enforcement at the same address as above, and to the Regional Administrator, NRC Region II, 101 Marietta Street, N.W., Suite 2900, Atlanta, Georgia 30323.
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After reviewing the Licensee's response, the NRC will determine whether further I
action is necessary to ensure compliance with regulatory requirements.
FOR THE NUCLEAR REGULATORY COMMISSION
'avus/h...-in7?
umes H. Sniezek eputy Executive Director for Nuclear
- Reactor Regulation, Regional Operations and Research Dated at Rockville, Maryland this y day of June 1991 i
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